Privacy Policy

Background

This Privacy Policy governs Focus Technology Group (NZ) Limited’s (referred to in this Privacy Policy as “we”, “our” or “us”) collection, use and disclosure of your personal information and has been prepared in accordance with our obligations and your rights set out in the Privacy Act 2020 (“Privacy Act”).

From time to time we may collect or request personal information from you in the course of providing you, or by you accessing and using, our Services (as described below). Personal information is any information about you that identifies you, or by which your identity can reasonably be ascertained.

Application of this Privacy Policy

This Privacy Policy applies to any personal information that we collect when you interact with us, including when you:

• visit any of our branches;
• use our online services;
• use any of our websites or mobile applications;
• register to receive regular marketing communications from us; and/or
• use any other services we provide now or in the future,

(together, these form “Services”).

In the event of any inconsistency between this Privacy Policy and other policies or terms and conditions that may apply to your use of any of the Services, the terms of this Privacy Policy will prevail.

We provide Services within New Zealand and Australia. Where we obtain personal information about Australian individuals that information remains subject to the Privacy Act and this Privacy Policy.

Information we collect

The personal information we may collect may include your:

• name, contact details (including those of your key IT personnel), billing information, address;
• credit references;
• details of communications we have had with you including email communications and phone conversations with our staff (which may be recorded to ensure we have an accurate record of your call);
• image (via photograph or film) as you move around our properties.
• Details of users, computers, servers and network infrastructure inside your business
• Contact information and the contents of your email

When you visit or use our website, we may also collect information including the IP address of your machine or device, the operating system and the browser your machine or device uses, your browser’s general wifi location, the date and time you are visiting and the pages you view. See the section “How we use cookies and usage monitoring software” below for more information.

How we collect information

Where possible we will collect personal information directly from you, for example when you contact us by phone, email or via our website, when you personally meet with our staff or agents or where you use our Services.

We (and any authorised third parties in accordance with this Privacy Policy) may also collect personal information:

• as part of our recruitment processes;
• when you submit an application for employment or contracting opportunities with us;
• by recording calls/electronic meetings you have with our staff;
• through the recording of your image on CCTV footage in and around our properties;
• when you subscribe to any of our newsletters, participate in surveys, competitions or promotions;
• through the use of cookies and usage monitoring software or google analytics when you use our website.

Information may also be collected about you from third parties or other sources if you have authorised that collection or that information is publicly available.

How we use cookies and usage monitoring software

Cookies are small text files that are placed in your browser by the websites you visit. They are widely used to help users navigate websites efficiently, to perform certain functions on the sites, and/or to provide site owners with information about how their sites are used. When you access our websites, social media pages and/or mobile apps, we may use cookies where they are required for particular features to work – for example, if you are a logged in user, to allow you to remain logged in whilst you complete certain tasks. Some information/Services may be unavailable if you chose to disable your browser from accepting cookies.

By using the Services, you consent to the storing and accessing of cookies or other information on your device in connection with your use of the website.

Our website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage. By using our website you consent to the processing of data about you by Google in the manner described in “How Google uses data when you use our partners’ sites or apps” which you can read at www.google.com/policies/privacy/partners.

How we store and protect your information

Your information will be held by us in one of our New Zealand or Australian locations. We will take reasonable steps to ensure your personal information is stored safely and securely. This includes taking reasonable steps to ensure the security of our electronic systems and passwords, our cloud servers and filing cabinets containing personal information.

Security of personal information is very important to us and we will take all reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure. However, communications over the internet, such as emails, are not secure, unless they have been encrypted. It is your responsibility to protect access to any emails you receive from us that provide access to your account.

How we use information we have collected

We collect personal information in order to provide you with, and allow you to access and use, the Services.

By accessing and using the Services, or by registering to receive marketing communications from us, you agree that we (and any authorised third parties in accordance with this Privacy Policy) may collect, store and use your personal information to do any of the following:

• enable us to provide the services you have contracted with us to provide;
• deal with your support requests, enquiries and any complaints about our services;
• allow you to access and view your account created to receive the services or marketing communications;
• develop and evaluate our products and services;
• provide information to you about our products and services and promotions or benefits which are being offered by us;
• communicate essential information such as warning you about cyber security issues;
• carry out activities required by law or regulatory requirements;
• administration or business functions such as processing your transactions and administering your account;
• consider employing you, for example, carrying out pre-employment checks and to meet our requirements as your employer (where applicable);
• for safety and security purposes;
• carry out credit checks; and
• such other purpose we make known to you at the time of collection of the personal information.

Disclosing your personal information

By using one or all of the Services you agree that we may disclose your personal information for any of the purposes listed in the above section (How we use information we have collected) to:

• a third party who is contracted to us to provide a particular service to you on our behalf;
• a third party who is contracted to us to provide a particular service to us;
• to our appointed payment provider to process your payments for purchases; and
• third parties when we believe in good faith that we are required to do so by law.

You consent to the disclosure of your personal information to the parties listed above.

Other than as outlined above, we will not share your personal information with, or sell or license it to, any other third party, except as required by law or where disclosure is necessary to prevent a threat to health, security or safety. However as detailed within Google’s privacy policy you should be aware that they may share information they have collected publicly and with their partners.

Direct marketing and consent to receiving messages

When you become a client of Focus and register to receive marketing communications from us, your name and contact details will be added to our database, and you consent to receiving messages from us by email, text message, or physical mail (depending on what information you provide us and your stated preferences).

All commercial electronic messages from us will contain an unsubscribe function if you no longer want to receive commercial electronic messages from us. You can unsubscribe from receiving emails from Focus at any time by clicking the unsubscribe link in any email you receive from us. We will endeavour to update your account preferences as soon as possible.

Data retention

Where we collect personal information from you we will only hold and use it for the duration it is required. Once we no longer need it we will securely delete the information within a reasonable timeframe.

Your rights to information we hold about you

You are entitled to request access to personal information that we hold about you and to request us to update or correct your personal information. We will disclose personal information to the relevant individual about whom the information relates where it can be readily retrieved, unless there is good reason (in accordance with the Privacy Act) for not doing so, including where such a disclosure would breach someone else’s rights to privacy and/or the law. We will make a correction if we think it is reasonable for us to do so. If we do not agree with your request, you can request us to take reasonable steps to attach a statement of the correction sought but not made to the relevant information.

To correct or update information we hold about you please contact our Privacy Officer, privacy@focus.net.nz. We will rely on the information that you have provided us so please ensure that information is accurate and kept up-to-date.

If you find that information we hold about you is incorrect, please contact us immediately and we will correct it. admin@focus.net.nz

Complaints

You have the right to complain if you feel that we have not responded to your requests to solve a problem regarding your personal information. You can make a complaint direct to our Privacy Officer; privacy@focus.net.nz.

You also have the right to make a complaint to the New Zealand Office of the Privacy Commissioner. Information about how to lodge a complaint is available on their website.

Changes to our Privacy Policy

We may make changes to this Privacy Policy from time to time and we will advise of such changes by posting an updated policy to our website.

We advise you to check back frequently to see any updates or changes. Unless otherwise stated, any changes to the Privacy Policy will take effect immediately upon being placed on the website and your continued use of the Services will represent an agreement by you to be bound the Privacy Policy as amended.

Last updated: 20^th May 2021